  SEQ CHAPTER \h \r 1 				

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES



  SEQ CHAPTER \h \r 1 						PC Code 	129098

		DP Barcode	D360713, D365942 & D365948

MEMORANDUM

DATE:	February 24, 2010

SUBJECT:	Tier I Estimated Drinking Waters Concentrations (EDWCs) of
Fluazinam and its Transformation Products for the Use in the Human
Health Risk Assessment for the Registration of the Following New Food
Uses: Lettuce, Apples, Carrots and Bulb Vegetables (Crop Subgroup 3-07A)

FROM:	José L. Meléndez, Chemist

		Environmental Risk Branch V

		Environmental Fate and Effects Division (7507P)  

THROUGH:	Mah T. Shamim, Branch Chief

		Environmental Risk Branch V

		Environmental Fate and Effects Division (7507P)

		

TO:		Laura Nollen, Risk Manager Reviewer

		Barbara Madden, Review Manager #05

		Daniel Rosenblatt, Branch Chief

		Risk Integration, Minor Use and Emergency Response Branch

		Registration Division (7505P)

AND:		Douglas Dotson, Ph.D., Chemist

Christina Swartz, Branch Chief

Registration Action Branch II

		Health Effects Division (7509P)

This memo presents the Tier I Estimated Surface Drinking Water
Concentrations and Estimated Ground Water Concentrations (EDWCs) for
Fluazinam and Fluazinam Total Residues (parent plus its major
transformation products), calculated using the Tier I aquatic models
FIRST and SCI-GROW, respectively, for use in the human health risk
assessment.  The registrant is seeking registration of the use of
fluazinam on lettuce, apples, carrots and bulb vegetables (Crop Subgroup
3-07A).

The Estimated Drinking Water Concentrations (EDWCs) for Fluazinam and
Fluazinam Total Residues were calculated based on a maximum application
rate of 4.50 lb a.i./A/ season of fluazinam on apples.  For the parent
fluazinam, the surface water acute value is 110 ppb, and the chronic
value is 0.744 ppb.  The groundwater screening concentration is 0.216
ppb of fluazinam.  For the total fluazinam residues (including the
parent compound), the surface water acute value is 117 ppb and the
chronic value is 19.8 ppb.  The groundwater screening concentration is
0.216 ppb.  These values represent upper-bound estimates of the
concentrations of the chemicals that might be found in surface water and
groundwater due to the use of fluazinam on apples.  EDWCs were
calculated for total fluazinam residues because the environmental fate
studies indicated that the parent compound forms transformation
compounds which have similar structure to the parent under most
conditions (as per MARC request, DP Barcode D272624, W. Cutchin,
4/23/2001).

Should the results of this assessment indicate a need for further
refinement, please, contact EFED as soon as possible so that the
Division may schedule a Tier 2 assessment.

Data Gaps:

The environmental fate database is substantially complete.  The
following have been identified as data gaps: 835.6100: Terrestrial Field
Dissipation.  The registrant submitted two terrestrial field dissipation
studies (MRID#s 45584207 and 45584208).  These studies are currently in
review.

And: 835.6100, 835.6200:  Environmental Chemistry Methods (ECMs) and
Independent Laboratory Validations (ILVs) for Soil, Water and Sediment. 
ECMs, along with successful confirmatory method trials (validation) by
an independent laboratory (i.e. ILVs), are required.  These ECMs should
have limits of quantitation for the residues of concern that are lower
than the relevant toxicological levels of concern.  The latter risk
assessments indicated concerns for organisms living in freshwater &
estuarine/ marine bodies of water, and for estuarine/ marine organisms
living in the benthos.  Therefore, ECMs for water and sediment are
required in addition to the ECM for soil.  The registrant is encouraged
to submit state-of-the-art ECMs; further, multi-residue methods (MRMs)
for soil, water and sediment are preferred.

EXECUTIVE SUMMARY 

Fluazinam’s CAS Name is
3-chloro-N-[3-chloro-2,6-dinitro-4-(trifluoromethyl)phenyl]-5-(trifluoro
methyl)-2-pyridinamine, its IUPAC Name is
3-chloro-N-(3-chloro-5-trifluoromethyl-2-pyridyl)-α,α,α-trifluoro-2,6
-dinitro-p-toluidine, its CAS Number is 79622-59-61, and its PC Code is
129098.  Fluazinam is a protectant and contact fungicide.  It is an
uncoupler of oxidative phosphorilation in the respiration chain
involving protonation/ deprotonation (it inhibits fungal respiration,
and the production of energy within the fungus).  Fluazinam is a phenyl
pyridinamine (dinitroaniline).  The structure consists of one phenyl
ring with two nitro groups, and a pyridine ring.  Both rings have a
trifluoromethyl group and are monochlorinated.  The rings are attached
by an amine group. 

Fig. 1. Structure of Fluazinam



The product containing fluazinam is Omega 500F Agricultural Fungicide
(EPA Reg. No. 71512-1).  It contains 40.0% fluazinam.  It is currently
used on potatoes, peanuts, edible-podded legume vegetables (except
peas), bushberry (crop subgroup 13B), brassica (cole) leafy vegetables,
ginseng, and dry, and succulent bean crop Subgroup 6B (except peas).  It
is being proposed in a Section 3 (IR-4) petition, for use on lettuce,
apples, carrots and bulb vegetables (Crop Subgroup 3-07A).  The
application methods vary with the crops.  For example, aerial
applications are allowed only on potatoes, but the material may be
applied by sprinkler irrigation, or, for brassica leafy vegetables, it
may be applied by soil incorporation prior to transplanting.  

This is a Tier I screening-level assessment using Tier 1 aquatic models
SCI-GROW and FIRST for groundwater and surface water, respectively.  It
was found that the worse case scenario was apples, with the highest
seasonal application rate, and the highest PCA.  In addition to the
EDWC’s for fluazinam, EDWC’s were calculated for total fluazinam
residues because the environmental fate studies indicated that the
parent compound forms transformation compounds which are similar in
structure to the parent under most conditions (for structures, refer to
Table A-1 of the Appendix).  EFED observed that fluazinam does not
undergo degradation.  Instead, it undergoes transformation into a series
of products, all of which resemble the parent by way of their chemical
structure.  For the modeling, the EFED assumed that the physicochemical
characteristics were similar for both the parent and its products (i.e.
the total toxic residue approach).

As indicated above, it was assumed that for the total residues of
fluazinam, the properties of fluazinam were applicable, and were similar
for all the metabolites.  For example, the solubility of fluazinam was
assumed to apply to the total residues as well.  It was found that the
solubility of fluazinam depends on the pH.  The solubility of the pH 11
solution was used in this assessment since it is the highest available
value.  Using this value resulted in an acute concentration that is
higher than the solubility of fluazinam at pH 7.  (Most environmental
conditions are close to neutral pH.)  This fact constitutes the source
of highest uncertainty to the assessment, it appears that the input
value could have a large impact on the acute concentration.  It was also
assumed that the mobility of fluazinam was the same to the total
residues; this is supported by mobility data for two of the metabolites
of fluazinam.

This assessment was based on the maximum application rate for the crop
(apples, 0.45 lb a.i./A), the maximum seasonal rate (4.5 lb
a.i./A/season), the minimum interval between applications (7 days), and
the highest PCA (87%).  This is the most conservative assumption.  The
total residues approach is also conservative, with uncertainties due to
unavailability of detailed degradate information.  At this time, the
persistence of fluazinam transformation products is uncertain because
the information about these compounds from terrestrial field dissipation
studies has been deemed invalid.  The aquatic metabolism studies signal
high persistence of such degradates and in the soil metabolism studies,
generally the degradates were present in relatively small amounts.  To
address this issue, two new terrestrial field dissipation studies have
been submitted and are currently in review.

No readily available monitoring data are available for fluazinam.  It is
likely that primary treatment may reduce the levels of fluazinam due to
its high level of binding and its tendency to hydrolyze at higher pHs,
but the level of reduction is unknown.

Table 1 provides a summary of the Tier 1 modeled drinking water
concentrations.  Should there be a need for additional refinements a
more definitive assessment, using the Tier 2 aquatic models may be
performed at the expenditure of additional resources.

Table 1.  Maximum Tier 1 Estimated Drinking Water Concentrations (EDWCs)
for drinking water assessment based on ground application of fluazinam.

DRINKING WATER SOURCE (MODEL USED) 	USE (rate modeled)	MAXIMUM ESTIMATED
DRINKING WATER CONCENTRATION  (EDWC)  ( ppb) 

Groundwater

(SCI-GROW) Fluazinam and Total Residues of Fluazinam (Including the
Parent Compound)	Apples (4.50 lb a.i./A/season)	Acute and Chronic	0.216

Surface Water

(FIRST) Fluazinam	Apples (4.50 lb a.i./A/season)	Acute	1101



Chronic	0.744

Surface Water

(FIRST) Total Residues of Fluazinam (Including the Parent Compound)
Apples (4.50 lb a.i./A/season)	Acute	1171



Chronic	            19.8

1. This value exceeds the solubility of fluazinam at pH 7 (71 ppb), but
is lower than the solubility at pH 11.

PROBLEM FORMULATION

This is a Tier I drinking water assessment that uses modeling and
monitoring data, if available, to estimate the ground water and surface
water concentrations of pesticides and transformation products in
drinking water source water (pre-treatment) resulting from pesticide use
on sites that are highly vulnerable.  This initial tier screens out
chemicals with low potential risk and provides estimated exposure
concentrations for the human health dietary risk assessment.

  

The last Tier 1 drinking water assessment was issued on 2/7/07, using
the FIRST and SCI-GROW models, with bushberries being the worst case
scenario.  The current most conservative scenario was now found to be
apples (seasonal application rate 4.50 lb a.i./A, divided into ten
applications, and broadcast spray application method).  The present
action triggers the need for a new drinking waters assessment because
the uses have a higher seasonal rate of application.

For fluazinam, the following drinking water hypothesis is being employed
for this assessment:

Fluazinam use in accordance with the label, results in potential
contamination of both, surface and ground water resources, with
fluazinam and its relevant transformation products.

The conceptual site model is a generic graphic depiction of the risk
hypothesis.  Through a preliminary iterative process of examining
available data, the conceptual model (i.e., the drinking water
hypothesis) has been refined to reflect the likely exposure pathways
that are most relevant and applicable to this assessment (refer to Fig.
2).

Fig. 2. Conceptual Model for Drinking Water Assessment for Fluazinam



Fluazinam is applied to the field via ground methods (for apples and
other crops) and ground and aerial methods (for potatoes only).  Crop
absorption may be important because fluazinam has a relatively high
tendency to bind, but crop uptake is not expected to be important (for
its relatively high Kd and KOC values). In addition, spray drift is an
important factor in the contamination of nearby surface waters because
fluazinam is applied via ground or aerial spray. As the field may be
kept irrigated and the soils are wet, large runoff events, accompanied
with erosion, may be a factor in horizontal movement due to the tendency
of the chemical to remain bound to the soils (high tendency to partition
with the soils).  Fluazinam shows low persistence in laboratory studies
in aquatic media, but its persistence is higher in soils.  It may be
available for moderate periods of time (on the order of several weeks to
several months) in soils; fluazinam total residues are persistent in
aquatic environments. Vertical movement to subsurfaces is not expected
to be very important in the dissipation of fluazinam despite its
moderate persistence in aerobic environments due to its level of
binding.  Volatilization is expected to be a relatively minor route of
dissipation for the active ingredient (fluazinam has a relatively small
vapor pressure and Henry’s Law Constant).  The degradates observed in
the laboratory studies included CAPA, G-504, HYPA AMPA, MAPA, DAPA and
DCPA, but not all of them are expected to be present in the aquatic
environment.  The major transformation products observed in the aquatic
metabolism studies include DCPA, HYPA, CAPA, DAPA and AMPA.  For
structures of the various transformation products of fluazinam, refer to
Table A-1 of the Appendix.

ANALYSIS

Use Characterization

A summary table of all use patterns, new uses and modeled uses, is
provided in Table 2.  The crop groups shaded gray are the proposed ones;
the bolded & underlined use is the modeled one (apples).  This
information is based on the current and proposed label of Omega 500F,
EPA Reg. No. 71512-1.

  SEQ CHAPTER \h \r 1 Table 2.  Use information for fluazinam (based on
Omega 500F label, EPA Reg. No. 71512-1).

USE	SINGLE  APP. RATE (lb. a.i./A)	NUMBER OF APPS.	SEASONAL APP. RATE
(lb. a.i./A)	INTERVAL BETWEEN APPS. (days)	APP. METHOD	PHI (days)

Lettuce (head and leaf)	1.00	1	1.00	N/A	Ground: foliar band, broadcast
spray or soil drench	For head lettuce 50; for leaf lettuce 30

Crop Subgroup 3-07A Bulb Vegetables (includes bulb daylily, bulb
fritillaria, bulb garlic, bulb great headed garlic, bulb serpent garlic,
bulb lily, bulb onion, bulb Chinese onion, pearl onion, bulb potato
onion, bulb shallot, and cultivars, varieties, and/or hybrids of these)
0.52	6	3.13	7 - 10	Ground, through sprinkler irrigation	7

Carrots	0.52	4	2.09	7	Ground	7

Apples	0.45	10	4.50	7 - 10	Broadcast spray	28

Peanut 	0.52-1.04	2	2.09	21	Ground, Sprinkler irrigation	Do not apply
w/in 30 d of threshing for harvest

Potato	0.18-0.26	7	1.82	7	Aerial, Ground, Sprinkler irrigation	14

Succulent Bean Crop Subgroup 6B (such as, but not limited to lima bean
and broad bean)	0.26-0.44	2	0.91	7	Ground, Sprinkler irrigation	14

Ginseng	0.52-0.78	4	3.13	7	Ground	30

Crop Subgroup 6A, Edible-Podded Legume Vegetables except peas, such as,
but not limited to: Phaseolus spp. Such as: runner bean, snap bean, wax
bean; Vigna spp. Such as: asparagus bean, Chinese longbean, moth bean,
yardlong bean; jackbean, and sword bean	0.26-0.44	2	0.91	7	Ground,
Sprinkler irrigation	14

Dry Bean Crop Subgroup 6C, except Peas and Soybeans (such as, but not
limited to dried cultivars of bean: Lupinus spp.; Phaseolus spp, such as
kidney beans, dry lima bean, navy bean, pinto bean; Vigna spp., such as
adzuki bean; and broad bean, such as lablab bean)	0.26-0.44	2	0.91	7
Ground, Sprinkler irrigation	30

Crop Subgroup 13-07B, Bushberry, such as, but not limited to: Aronia
berry, blueberry (highbush and lowbush), Chilean guava, currant
(Buffalo, black, red, and Native), elderberry, European barberry,
gooseberry, highbush cranberry, honeysuckle, huckleberry, jostaberry,
juneberry, lingonberry, salal, and sea buckthorn	0.65	6	3.90	7	Ground	30

Crop Group 5, Brassica (Cole) Leafy Vegetables, such as, but not limited
to: broccoli; broccoli raab (rapini); Chinese cabbage (napa);
cauliflower; collards, kale; mizuna; mustard spinach; turnip greens;
Chinese broccoli; Brussels sprouts; Chinese cabbage (bok choy); Chinese
mustard cabbage; cavalo broccoli; kohlrabi; mustard greens; rape greens
[Transplant 6.45 fl oz/100 gal or presumably 0.64 lb a.i./A]

Soil incorpo-ration 1.36 at a soil depth of 6-8 in	1	2.00	N/A	Soil
drench after transplantingor soil incorporation (transplant the
seedlings into the treated band	20;

50 for heading vegetables such as cabbage and broccoli



Fluazinam may be applied through sprinkler irrigation (through center
pivot, motorized lateral move, traveling gun, solid set or portable
irrigation systems); however, it can also be soil incorporated before
transplant, for Crop Group 5, brassica (cole) leafy vegetables, in soils
with low infiltration rates.  The label requires a buffer zone of 25 ft
within permanent bodies of water (lakes, reservoirs, rivers, permanent
streams, marshes or natural ponds, and estuaries) so as to allow growth
of a vegetative filter strip.  The product should not be applied by
aerial equipment within 150 ft of estuarine/ marine areas (aerial
applications are currently allowed only for potatoes).  The product does
not require a similar buffer zone for aerial applications on freshwater
bodies of water (for freshwater bodies of water, the 25-ft buffer zone
applies).

The four newly proposed uses are lettuce, bulb vegetables (Crop Subgroup
3-07A), carrots and apples.  Ground application methods are proposed for
all those crops.  The use pattern selected for modeling was apples.  It
is noted that the highest seasonal application rate is 4.50 lb a.i./A
applies to apples; meanwhile, the individual single application rate is
not the highest of all crops.  The intervals between applications are 7
days.  It is applied by broadcast spray, which may cause drift towards
the index reservoir, it also has the highest PCA (default, 87%).   With
ten applications, at seven-day interval, it is likely that this scenario
will provide the highest acute and chronic exposure.

Fate and Transport Characterization

A detailed summary of physicochemical and environmental fate/transport
properties of fluazinam, including measured parameters, values, data
sources, and comments, is provided in Table 3.



yl)-α,α,α-trifluoro-2,6-dinitro-p- toluidine

Henry’s Law Constant	6.73 x 10-7 atm-m3/mol at pH 7	PMRA Reg. Note
REG2003-12

Octanol/Water Partition & log KOW	3620    &   3.56   (at 20°C)	MRID
42248403

Persistence:  

                                                                
Fluazinam                  Fluaz.+Degradates           

Hydrolysis t1/2	   pH 5

pH 7

pH 9	stable

42 days

6   days	stable

stable

stable	MRID  42208412 (a)

Photolysis  t1/2 in water	2.5 days, dark control ≈stable	one degradate
(G-504)	MRID  44807312, 43521009, 45584204 (a)

on soil	35.0 days, value corrected for dark control	degradates at ≤10%
of the applied	MRID  44807313, 45584204 (a)

Soil metabolism Aerobic t1/2	114-132 days for samples treated at 1 kg/ha
(5.56 ppm)	degradates at ≤10% of the app.; HYPA was 11.4% at 30 days
(for soil treated at 5 kg/ha)	MRID  42208413, 42208414 (a)

Soil metabolism Anaerobic t1/2	SL flooded at time 0 days – half-life 4
days;

SL flooded at 30 days – half-life 32 days	HYPA was 11.0% at 60 days
for the spl. flooded at 30 days.  MAPA was up to 29.8% for the sample
flooded at time 0.	MRID  42208413, 42208414 (s)

Aquatic metabolism  Aerobic DT50	4.0-7.4 hours	51-71 days	MRID  44807314
(a)

Aquatic metabolism  Anaerobic t1/2	≈ ⅓ day (or approximately 8
hours)	stable	MRID  43521010 (a)

Mobility/Adsorption-Desorption

Batch Equilibrium - Unaged

Aged Soil Column Leaching	4 soils    KF=11-44    KFOC=1700-2300

       KF, des=34-507  KFOC, des=7000-19900

- - - - - -

0.66% in leachate	MRID  42248628, 42974913 (a)

MRID  42208415 (a)

Batch Equilibrium HYPA

Batch Equilibrium CAPA	6 soils    Kd=6.6-51  KOC=640-3200

             KF=4.3-26  KFOC=450-1700

 Increasing adsorption w. increasing pH

- - - - - - -

4 soils     KF=4.9-67  KFOC=1289-3784

Studies on HYPA and CAPA were conducted w. sterile soils.	MRID  43528201
(a)

MRID  44807315 (s)



Field Dissipation

Terrestrial Dissipation

t1/2 in soil surface layer	Range from 9 to 49 days:  Ephrata, WA: DT50~9
days loamy sand, pinto beans; Kempton, ND: half-life=49 days, sandy
loam, beans; Porterville, CA: half-life=20 days, loamy sand, beans;
Montezuma, GA The degradation was biphasic.	MRID  44807318, 44807320,
44807316 (s)

Bioaccumulation

Accumulation in Fish, max. BCF	273-348 X for fillet portion

960-1220 X for whole fish

1410-1850 X for non-edible

~67% of the residues eliminated from the fillet during the 21-day
depuration phase	MRID  43521012 (a)

(a) = acceptable or core study that fulfills guideline requirement; (s)
= supplemental study; (u) = unacceptable study. Where two values are
stated, they may correspond to two radiolabel positions.



Fluazinam appears to degrade at moderate rates in aerobic soils (132
days), but it is more rapidly transformed into other compounds of
similar backbone structure in high pH solutions (6 days at pH 9) or in
aerobic (≤7.4 hr) or anaerobic aquatic (~8 hr) media.  The
transformation products of fluazinam appear to be relatively persistent
under most conditions.  Fluazinam may photolyse relatively rapidly in
water (2.5 days) to form a tricyclic compound (G-504).  The total
fluazinam residues (fluazinam and its transformation products) are
persistent in most environments (stable to hydrolysis at all pHs,
aerobic aquatic metabolism 51-71 days, relatively stable in anaerobic
aquatic environment) and are likely to reach aquatic media as a totality
through runoff.  Since fluazinam does not alter substantially its
backbone structure in the environment, but instead, goes through slight
transformations of functional groups, EFED considers parent and
transformation products together when making assessments.  Based on the
properties of the chemical, applications of fluazinam are likely to
reach the target (the crop), but drift is also possible.  The total
residues of fluazinam may reach adjacent bodies of water via runoff
events and may be persistent.  The chemical has a low vapor pressure
(8.25x10-6 mm Hg), and a relatively low Henry’s Law constant (6.73 x
10-7 atm-m3/mol).  Due to the fact that it appears to show short half
lives in aquatic media, and it binds to soils, EFED believes that the
chemical would not volatilize substantially.  While the parent and two
transformation products, HYPA and CAPA, have relatively low mobility,
indicating low potential for ground water contamination, there is
uncertainty about the other transformation products and further
information on them was required in a new terrestrial field dissipation
study.  Two such studies (MRID#’s 45584207 & 45584208) are currently
in review.

Hydrolysis  tc "i. Hydrolysis " \l 3 

The hydrolysis of fluazinam is pH dependent.  It was relatively stable
at pH 5, and hydrolyzed with half-lives of 42 and 6 days at pHs of 7 and
9, respectively.  The major degradate was CAPA.

Photolysis  tc "ii. Photolysis " \l 3 

Fluazinam photolyses in aqueous solutions, mainly to G-504, a tricyclic
compound, and possibly one or more other unidentified products).  The
half-life obtained in the study was 2.5 days.  The soil photolysis, on
the other hand, the half-life was 22 days (compared to 69 days for the
dark control).  The dark control corrected half-life is 35 days.

Metabolism  tc "iii. Metabolism " \l 3 

The metabolism of fluazinam appears to be moderate in a sandy loam soil
treated at 1 kg/ha (5.56 ppm) (DT50 ≤ 30 days). The calculated
half-life (linear regression, assuming first order kinetics) was about
114-132 days, which is in agreement with the fact that after 361 days,
6.8 and 9.5% of the applied fluazinam remained intact for the
14C-pyridyl and 14C-phenyl labels, respectively.  No major metabolites
were observed.  The sandy loam treated at 5 kg/ha yielded a half-life of
227 days.  For the samples treated at the high rate, Compound XII (HYPA)
was observed at up to 11.4% at 30 days posttreatment.  A loamy sand
treated at 1 kg/ha yielded a half-life of 165 days with no major
metabolites.  No major degradation products were observed in the samples
treated at 1 kg/ha, but a major fraction (~41%) was bound material at
the end of the study (day 361).

Sediment/Water Systems  tc "iv. Sediment/Water Systems " \l 3 

The aerobic aquatic and the anaerobic aquatic metabolism studies
resulted in very short half-lives (4 – 8 hours).  In such studies,
various metabolites were formed.  All the major transformation products
observed have structures that resemble the structure of the parent.  The
sum of the concentration of the parent, plus the concentrations of the
transformation products (total fluazinam residues), decreased very
slowly under both aerobic (half-lives 51-71 days) and anaerobic
(relatively stable) aquatic conditions.  The major transformation
products observed in these studies include DAPA, SDS-67200, AMPA, DCPA,
and CAPA.

Mobility  tc "v. Mobility " \l 3 

In batch equilibrium studies, fluazinam is slightly mobile in four soils
tested.  KFOC values ranged from 1705-2316.  Similarly, an available
soil column leaching study of aged fluazinam indicated low mobility of
the residues of fluazinam.  Less than 1% of the applied radiocarbon was
found in the leachates and >>80% remained at the top of the soil
columns.  There is mobility information for two of the transformation
products of fluazinam: HYPA and CAPA.  Of them, HYPA appeared to be
moderately to slightly mobile (KFOC=450-1700, 6 soils), and CAPA
appeared to be slightly mobile, but generally less mobile than the
parent (KFOC=1289-3784, 4 soils).  The latter two batch/equilibrium
studies were conducted on sterile soils.

Field Dissipation tc "vi. Field Dissipation " \l 3 

Four terrestrial field dissipation studies were submitted by the
registrant.  Such studies were found to provide only limited
supplemental information.  In particular, the data about the degradates
is very questionable due to poor recoveries in a storage stability
study.  In general, it appeared that parent fluazinam degraded
moderately rapidly in studies conducted in Ephrata, WA, Kempton, ND,
Porterville, CA, and Monctezuma, GA.  The dissipation half-lives ranged
from 9 to 49 days.  These half-lives are in agreement with the aerobic
soil metabolism half-lives.  At this time, the EFED has two newly
submitted terrestrial field dissipation studies, which are in review.

Bioaccumulation  tc "vii. Bioaccumulation " \l 3 

Fluazinam demonstrated some potential to bioaccumulate in fish.  The
maximum BCF’s were 348X for fillet, 1220 for whole fish, and 1850 for
viscera, all of which were obtained with the phenyl labeled material. 
Fish residues identified included the parent compound, AMPA, MAPA and
DAPA.  Depuration was moderately slow.  More than 67% of the residues
were eliminated from the fillet during the 21-day depuration phase.

The fate and transport characterization also includes the various
degradation and transformation products formed by each process in the
studies reviewed.  This is of particular importance for fluazinam, which
forms metabolites of similar structure than the parent compound.  Table
4 provides a summary of these transformation products.

Table 4.  Summary of degradate formation from degradation of fluazinam.

STUDY TYPE	DEGRADATE and MAXIMUM CONCENTRATION	SOURCE

	CAPA, G-504, HYPA AMPA, MAPA, DAPA, DCPA (% applied)

	Hydrolysis	CAPA 34% at 28 days pH 7; 84-85% at 20 days at pH 9	–	–	
 MRID: 42208412.

Aqueous Photolysis	G-504 was 14.0-17.1% by 7-10 days	_	–	  MRID:
444807312, 43521009, 45584204.

Soil Photolysis	HYPA, detected > dark control	AMPA detected > dark
control	–	  MRID: 44807313, 45584204.

Aerobic Soil Metabolism	HYPA, MAPA and DAPA detected (in the SL soils,
applied at 1 kg/ha)	  MRID: 42208413, 42208414.

Anaerobic Soil Metabolism	HYPA was 11.0% at 60 days for the SL flooded
at 30 days	MAPA was 29.8% at 14 days for the SL flooded at zero time	–
  MRID: 42208413, 42208414.

Aerobic Aquatic Metabolism	CAPA 12.6% at 72 hr	DAPA: 19.0% by 240 hr
DCPA: 11.3% at 24 hr	MRID: 44807314.

Anaerobic Aquatic Metabolism

	AMPA 24.2% at 0.2 day	DAPA: 32.7% at day 30	SDS-67200 39.6% by day 14
MRID: 43521010.

Terrestrial Field Dissipation	MAPA, CAPA, and HYPA were monitored;
however, there were problems with the storage stability data for the
degradates.	MRID: 44807318, 44807320, 44807316, 44807319, 44807317.



Drinking Water Exposure Modeling

  SEQ CHAPTER \h \r 1 

Models

A brief description of the models used follows.

SCI-GROW (v 2.3, 8/5/03) (Screening Concentration in Ground Water) is a
regression model used as a screening tool to estimate pesticide
concentrations found in ground water used as drinking water.  SCI-GROW
was developed by fitting a linear model to groundwater concentrations
with the Relative Index of Leaching Potential (RILP) as the independent
variable.  Groundwater concentrations were taken from 90-day average
high concentrations from Prospective Ground Water studies; the RILP is a
function of aerobic soil metabolism and the soil-water partition
coefficient.  The output of SCI-GROW represents the concentrations that
might be expected in shallow unconfined aquifers under sandy soils,
which is representative of the ground water most vulnerable to pesticide
contamination likely to serve as a drinking water source.  (Ref. 1 & 2)

FIRST (v 1.1.1, 3/26/08) (FQPA Index Reservoir Screening Tool) is a
metamodel of PRZM and EXAMS used as a screening tool to estimate
pesticide concentrations found in surface water used as drinking water. 
FIRST was developed by making multiple runs of PRZM using varying
sorption coefficients and determining the concentration in the EXAMS
index reservoir scenario after a two-inch single storm event.  (The
Index Reservoir is a standard water body used by the Office of Pesticide
Programs to assess drinking water exposure (Office of Pesticide
Programs, 2002).  It is based on a real reservoir (albeit not currently
in active use as a drinking water supply), Shipman City Lake in
Illinois, that is known to be vulnerable to pesticide contamination.) 
The single runoff event moves a maximum of 8% of the applied pesticide
into the reservoir.  This amount can be reduced by degradation or
effects of binding to soil in the field.  Additionally, FIRST can
account for spray drift and adjusts for the area within a watershed that
is planted with the modeled crop (Percent Cropped Area).   Spray drift
(modeled as direct deposition of the pesticide into the reservoir) is
assumed to be 16% of the applied active ingredient for aerial
application, 6.3% for orchard air blast application, and 6.4% for other
ground spray application. Despite being a single event model, FIRST can
account for spray drift from multiple applications.  The default
agricultural Percent Cropped Area (PCA) is 87%.  The PRZM scenario used
for FIRST development was among the most vulnerable, and thus resulting
surface water concentrations represent the upper bound values on the
concentrations that might be found in drinking water from the use of a
pesticide.  (Ref. 1, 3 & 4)

For volatile and semi-volatile compounds, Tier I modeling will tend to
over-estimate surface water EDWCs because there are no parameters in
FIRST that explicitly take into account volatility (ie., no vapor
pressure or Henry’s Law constant inputs).  Therefore, in reality, more
of the compound will be volatilizing than Tier I can account for.  If
drinking water levels of concern are exceeded for over-estimated Tier I
surface water EDWCs, Tier II modeling will be able to refine these EDWCs
by including volatility, Henry’s Law, diffusion in air, and enthalpy
considerations.  Since SCI-GROW is a regression model developed from
actual pesticide data with a range of volatilities, systematic
conclusions cannot be drawn about over or underestimation of groundwater
EDWCs at Tier I. 

Modeling Approach and Input Parameters

Tables of modeling parameter input values for SCI-GROW and FIRST (Tables
5 & 6, respectively) are based on the current input parameter guidance
(Ref. 5).

In addition to the EDWC’s for fluazinam, EDWC’s were estimated for
the total fluazinam residues, because the environmental fate studies
indicated that the parent compound forms transformation compounds which
are similar in structure to the parent under most conditions.  The input
parameters were selected according to the similarity observed in the
mobility characteristics of fluazinam, HYPA, and CAPA.  

It was observed that the KOC model was better to describe the mobility
of fluazinam.  For SCI-GROW, the median value was used, while, for
FIRST, the lowest non-sand value was selected.  Only one value of
aerobic soil metabolism was available (it was used in SCI-GROW, and
three times the value was used in FIRST.  Two values of aerobic aquatic
metabolism were available.  For FIRST, the 90th percentile of the upper
confidence bound on the mean was calculated.  It is noted that the input
value for the aerobic aquatic metabolism of the parent is only 0.454
days (10.9 hours), while for the total residues, it is 91.8 days.  A
ground application method was selected (with 6.4% drift).  The maximum
available solubility value, at 20-25ºC was used in modeling, as per
current guidelines.  This solubility applies to a pH 11.  It is noted
that the solubility of fluazinam is pH dependent.  

  

For the total residues, the half-life was calculated taking into
consideration the transformation products plus fluazinam.  This applied
to the aerobic aquatic metabolism (as indicated earlier, 91.8 days for
total residues vs. 0.454 days for fluazinam), and the hydrolysis
(relatively stable for total residues vs. 42 days for the parent).  For
the hydrolysis study, the transformation product that is formed is CAPA.
 In the aerobic aquatic metabolism study, the transformation products
formed are DCPA, CAPA, and DAPA, plus various minor transformation
products. For other parameters, in the absence of a suitable value, it
was assumed that the value for fluazinam was similar to that for the
total residues because they had similar structures (e.g. for the
solubility).

Table 5. SCI-GROW (v 2.3) input parameter values for fluazinam and total
residues of fluazinam, use on apples1.

PARAMETER (units)	FLUAZINAM	TOTAL RESIDUES	SOURCES AND COMMENTS

Maximum Application Rate (lb a.i./A)	0.45	Proposed label.

Number of Applications per Year	10	Proposed label.  Represents
most-conservative scenario in which the total maximum rate is applied in
six applications.

Organic Carbon Partition Coefficient (Koc; mL/g)	1904.5	Represents the
median value of four values ranging from 1705 to 2316 mL/g for the
parent compound. 

Aerobic Soil Metabolism Half-life (days)	132	Represents one value for
the aerobic soil metabolism of the parent compound.

1 Parameters are selected as per Guidance for Selecting Input Parameters
in Modeling the Environmental Fate and Transport of Pesticides; Version
II, February 28, 2002.



Table 6. FIRST (v 1.1.1) input parameter values for fluazinam and total
residues of fluazinam, use on apples1.

PARAMETER (units)	FLUAZINAM	TOTAL RESIDUES	SOURCES AND COMMENTS

Application Rate (lb a.i./A)	0.45	0.45	Proposed label.

Number of Applications	10	10	Proposed label.

Interval between Applications (days)	7	7	Proposed label.

Percent Cropped Area (decimal)	0.87	0.87	National default.

Soil Partition Coefficient (Kd; (mL/g) or KOC (mL/gOC))	1894	1894
Represents the lowest non-sand KOC value among four values ranging from
1705 to 2316 mL/g.  The KOC model is better for this chemical. 

Aerobic Soil Metabolism Half-life (days)	396	396	Determined by
multiplying the calculated half-life (132 days) by 3 to account for the
uncertainty associated with using a single value.

Wetted in?	No	No	Proposed label.

Depth of Incorporation (inches)	0.0	0.0	Proposed label.

Method of Application	Ground application	Ground application	Proposed
label.

Solubility in Water at pH 11 (mg/L or ppm)	350	350	Maximum available
value, at 20-25ºC.

Aerobic Aquatic Metabolism Half-life (days)	0.454	91.8	 Represents the
90th percentile of the upper confidence bound on the mean of two
half-life values (4.0 hr and 7.4 hr: mean 5.7 hr, std. dev. 2.40 hr, the
value is 10.9 hr or 0.454 days).  For total residues two half-lives (51
and 71 days: mean 61 days, std. dev. 14.14 days)

Hydrolysis Half-life @ pH 7 (days)	42	Stable	The transformation product
CAPA reaches a maximum at the end of the study at pH 7.

Aquatic Photolysis Half-life  @ pH 7 (days)	2.5	2.5	From aqueous
photolysis study

1 Parameters are selected as per Guidance for Selecting Input Parameters
in Modeling the Environmental Fate and Transport of Pesticides; Version
II, February 28, 2002.



The Percent Cropped Area (PCA) used was the National Default of 0.87; it
is intended for use on crops for which no PCA has been developed. 
Options for Tier I on a national scale are cotton, wheat, corn,
soybeans, or default.  Regional PCAs are a Tier II tool intended for
refined assessment. (Ref. 6)

Modeling Results

Table 7 summarizes the modeling results for all model runs.

Table 7.  Maximum Tier I Estimated Drinking Water Concentrations (EDWCs)
for drinking water risk assessment based on ground application of
fluazinam.

DRINKING WATER SOURCE (MODEL USED) 	USE (rate modeled)	MAXIMUM ESTIMATED
DRINKING WATER CONCENTRATION  (EDWC)  ( ppb) 

Groundwater

(SCI-GROW) Fluazinam and/or Total Residues of Fluazinam	Apples (4.50 lb
a.i./A/season)	Acute and Chronic	0.216

Surface Water

(FIRST) Fluazinam	Apples (4.50 lb a.i./A/season)	Acute	110



Chronic	0.744

Surface Water

(FIRST) Total Residues of Fluazinam	Apples (4.50 lb a.i./A/season)	Acute
117



Chronic	            19.8



The SCI-GROW concentration (ppb) represents the groundwater
concentration that might be expected in shallow unconfined aquifers
under sandy soils. The output is used for both acute and chronic
endpoints.

The FIRST concentrations (ppb) represent untreated surface water
concentrations.  The one-in-10-year peak day concentration is used for
acute endpoints and the one-in-10-year annual average concentration is
used for chronic endpoints. 

The estimated concentrations provided in this assessment are
conservative estimates of concentrations in drinking water.  If dietary
risks require refinement, higher tiered crop-specific and
location-specific models and modeling scenarios can be used.

Monitoring Data

No readily available monitoring data are available for fluazinam.  In
general, monitoring data provide different kinds of information than
modeling estimates.  For example, monitoring data consist of actual
information from the field, reflecting current use pattern and usually
underestimating frequency of occurrence.  Monitoring data does not
always include peak values, and inputs for monitoring cannot be adjusted
as modeled ones can.  In addition, monitoring is often conducted for
purposes other than characterizing exposure from a particular pesticide,
and as a consequence is used to complement modeling rather than to
refine it.  In general, a useful interpretation of monitoring values
requires in-depth assessment of the data, which is beyond the scope of a
Tier I assessment.

Drinking Water Treatment

It is likely that primary treatment may reduce the levels of fluazinam
due to its tendency to bind.  However, there is no information available
at this time to determine the levels of reduction.  Fluazinam is very
short lived in aquatic environments, forming various other
transformation products, which are more persistent.  Softening of
drinking water will generally result in an increase in pH.  Fluazinam is
more susceptible to hydrolysis under alkaline conditions; therefore,
softening may result in increased dissipation from hydrolysis. (Ref. 9) 

CONCLUSIONS 

This is a Tier I level drinking waters analysis, refinements may be
available should they be needed.  In addition to the EDWCs for
fluazinam, EDWCs were estimated for total fluazinam residues because the
environmental fate studies indicated that the parent compound forms
transformation compounds which are structurally very similar to the
parent under most conditions (for structures, refer to Table A-1 of the
Appendix).  EFED observed that fluazinam was not undergoing degradation.
 Instead, it was undergoing transformation into a series of products,
all of which resembled the parent in their chemical structure and were
more persistent (this is particularly true for the aquatic metabolism
studies).  For the modeling, the EFED assumed that the physicochemical
characteristics were similar for both the products and the parent.  This
is named total toxic residue approach, which was taken as opposed to the
approach that follows the formation/ decline of the residues or the
approach that assumes an equivalent application rate for each
metabolite.  The two latter approaches require more data than are
currently available.

Exposure to fluazinam and its residues are possible due to spray drift
or runoff.  Both the aerobic and anaerobic aquatic metabolism studies
show half-lives of ≤8 hours for fluazinam, with the formation of
various metabolites which are much more persistent in such media.  In
soils, fluazinam is more persistent than in aquatic systems (132 days). 
Therefore, exposure to the parent is more likely in soils.  In aquatic
environments, it appears that the major exposure will be to the
metabolites.

The acute levels of fluazinam in surface drinking waters was 110 ppb,
while the chronic level was 0.744 ppb.  The groundwater concentration of
fluazinam, suitable for acute and chronic exposure is 0.216 ppb.

For the total toxic residues, the acute levels of surface drinking
waters was 117 ppb, the chronic level was 19.8 ppb (of total residues). 
The groundwater concentration of total toxic residues of fluazinam,
suitable for acute and chronic exposure is 0.216 ppb.

It was assumed that for the total residues, the properties of fluazinam
were applicable, and were similar for all the metabolites.  For example,
the solubility of fluazinam was assumed to apply to the total residues
as well.  It was found that the solubility of fluazinam depends on the
pH.  It is higher when the pH is higher (0.025 ppm at pH 5.5, 0.071 ppm
at pH 7.0, and 350 ppm at pH 11.0).  The solubility of the pH 11
solution was used in this assessment since it is the highest available
value at 20-25ºC, as per current guidelines.  Use of this value
resulted in an acute concentration that is higher than the solubility of
fluazinam at pH 7.  It is noted that most environmental conditions are
close to neutral pH.  This fact brings uncertainty to the assessment
and, since the acute value was greater than the solubility of the
compound, it appears that the input value could have a high impact on
the results (particularly on the acute value).

Another example of the assumption that the properties of fluazinam apply
to the total residues is the mobility.  The mobility may be slightly
different for each transformation product.  It was found that the KOC
model was more suitable to describe the mobility of fluazinam than the
Kd model.  The batch equilibrium studies performed on the degradates
HYPA and CAPA show that the mobility of such metabolites is similar to
that of the parent (for the parent, KFOC=1700-2300; for HYPA,
KFOC=450-1700; and for CAPA, KFOC=1289-3784, refer to Table 3). 
Nonetheless, the studies conducted on HYPA and CAPA were conducted on
sterile soils.

The aerobic soil metabolism input value for the FIRST model was
determined by multiplying the available half-life (132 days) by 3 to
account for the uncertainty associated with using a single value.  This
is considered a conservative assumption for the model.

This assessment was based on the maximum application rate for the crop
(apples, 0.45 lb a.i./A), with the maximum seasonal rate (4.5 lb
a.i./A/season), with the minimum interval between applications (7 days),
and the highest PCA (0.87 or 87%).  For apples, the maximum application
rate of 0.45 lb a.i./A is recommended for certain species (Bitter rot,
Black rot, Brooks spot, Cedar apple rust, Alternaria blotch, White rot,
Quince rust, Two-spotted spider mite, European red mite and Apple rust
mite).  Meanwhile, for Apple Scab, Flyspeck and Sooty blotch, the
recommended application rate range is 0.33 to 0.45 lb a.i./A and the
interval between applications is 7 to 10 days.  The proposed label
indicates that “the high rate and shortest intervals should be used
for more susceptible varieties and heavy disease pressure.”  The
maximum application rate and the crop scenario (apples) may not be
representative for all the crops registered or proposed on a national
scale basis.  It is uncertain whether apples will represent a major use
for fluazinam.  However, this use is the most conservative assumption.

The total residues approach is conservative, with uncertainties due to
unavailability of detailed degradate information.  A more definitive
assessment, using the Tier 2 aquatic models may be performed at the
expenditure of additional resources, and given the availability of
additional data.  The assessment could involve input from additional
studies (not available at this time, e.g. the detailed formation and
decline data for the metabolites) and refine the PCAs (e.g., by using
regional PCAs).  Also, typical application rates may be used, when and
if available.

No readily available monitoring data are available for fluazinam.  It is
likely that primary treatment may reduce the levels of fluazinam due to
its tendency to bind and its highest susceptibility to hydrolysis under
alkaline conditions.  However, there is no information available at this
time to determine the levels of reduction.  Furthermore, fluazinam is
very short lived in aquatic environments, but it forms various other
transformation products, which are more persistent in the media.

*****************************************************************

References:

Policy Establishing Current Versions of Exposure Models and
Responsibility for Model Maintenance (11/06/2002)

SCIGROW: Users Manual (11/01/2001, revised 08/23/2002)

FIRST Users Manual (08/01/2001)

FIRST: A Screening Model to Estimate Pesticide Concentrations in
Drinking Water (05/01/2001)

Guidance for Selecting Input Parameters in Modeling the Environmental
Fate and Transport of Pesticides, Version II (02/28/2002) 

  SEQ CHAPTER \h \r 1 Use of the Index Reservoir and Percent Crop Area
in EFED Drinking Water Assessments (12/01/1999)

Golf Course Adjustment Factors for Simulated Aquatic Exposure
Concentrations (06/01/2005)

  SEQ CHAPTER \h \r 1 Policy for Estimating Aqueous Concentrations from
Pesticides Labeled for Use on Rice (10/29/2002)

The Incorporation of Water Treatment Effects on Pesticide Removal and
Transformations in Food Quality Protection Act (FQPA) Drinking Water
Assessments  (10/25/2001)

*****************************************************************

APPENDIX

Table A-1. Fluazinam and Various Transformation Products

Common Name	Chemical Name	Structure

Fluazinam	CAS Name: 3-chloro-N-[3-chloro-2,6-dinitro-4-(trifluoromethyl)
phenyl]-5- (trifluo-romethyl)-2-pyridinamine;

IUPAC Name: 3-chloro-N-(3-chloro-5-trifluoromethyl-2-
pyridyl)-α,α,α-trifluoro-2,6-dinitro-p-toluidine	

CAPA	3-chloro-6-(3-chloro-2,6-dinitro-4-trifluoromethyl
anilino)nicotinic acid;

5-chloro-6-(3-chloro-α,α,α-trifluoro-2,6-dinitro-p-toluidino)nicotini
c acid	

DAPA
3-chloro-N4-(3-chloro-5-trifluoromethyl-2-pyridyl)-α,α,α-trifluorotol
uene-3,5,5-triamine;
3-chloro-2(2,6-diamino-3-chloro-α,α,α-trifluoro-p-toluidino)-5-(trifl
uoromethyl) pyridine	

AMPA
2-(6-amino-3-chloro-α,α,α-trifluoro-2-nitro-p-toluidino)-3-chloro-5-(
trifluoromethyl)pyridine	

DCPA	6-(4-carboxy-3-chloro-2,6-dinitroanilino)-5-chloronicotinic acid	

MAPA
3-chloro-N4-(3-chloro-5-trifluoromethyl-2-pyridyl)-5-nitro-α,α,α-trif
luoro-toluene-3,4-diamine	

HYPA,

Compound XII
5-[[3-chloro-5-(trifluoromethyl-2-pyridyl]amino]-α,α,α-trifluoro-4,6-
dinitro-o-cresol	

G-504
4,9-dichloro-6-nitro-8-(trifluoromethyl)pyrido-[1,2-α]-benzimidazole-2-
carboxylic acid	





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ࠀTAL FATE AND EFFECTS DIVISION

                 OFFICE OF PESTICIDE PROGRAMS

             U.S. ENVIRONMENTAL PROTECTION AGENCY

                        SCREENING MODEL

                FOR AQUATIC PESTICIDE EXPOSURE

 

 SciGrow version 2.3

 chemical:Fluazinam

 time is 11/ 4/2009  12:10:11

 -----------------------------------------------------------------------
-

  Application      Number of       Total Use    Koc      Soil Aerobic

  rate (lb/acre)  applications   (lb/acre/yr)  (ml/g)   metabolism
(days)

 -----------------------------------------------------------------------
-

      0.450          10.0           4.500      1.90E+03      132.0

 -----------------------------------------------------------------------
-

 groundwater screening cond (ppb) =   2.16E-01 

 ***********************************************************************
*

RUN No.   1 FOR Fluazinam        ON   Apples        * INPUT VALUES *

--------------------------------------------------------------------

RATE (#/AC)   No.APPS &   SOIL  SOLUBIL  APPL TYPE  %CROPPED INCORP

ONE(MULT)    INTERVAL    Koc   (PPM )   (%DRIFT)     AREA    (IN)

--------------------------------------------------------------------

0.450(  4.261)  10   7    1894.0  350.0   GROUND( 6.4)  87.0   0.0

FIELD AND RESERVOIR HALFLIFE VALUES (DAYS)

--------------------------------------------------------------------

METABOLIC  DAYS UNTIL  HYDROLYSIS   PHOTOLYSIS   METABOLIC  COMBINED

(FIELD)  RAIN/RUNOFF  (RESERVOIR)  (RES.-EFF)   (RESER.)   (RESER.)

--------------------------------------------------------------------

396.00        2           0.00    2.50-  310.00    0.45       0.45

UNTREATED WATER CONC (MICROGRAMS/LITER (PPB)) Ver 1.1.1  MAR 26, 2008

--------------------------------------------------------------------

PEAK DAY  (ACUTE)      ANNUAL AVERAGE (CHRONIC)

CONCENTRATION             CONCENTRATION

--------------------------------------------------------------------

110.468                      0.744



RUN No.   2 FOR Total Res        ON   Apples        * INPUT VALUES *

--------------------------------------------------------------------

RATE (#/AC)   No.APPS &   SOIL  SOLUBIL  APPL TYPE  %CROPPED INCORP

ONE(MULT)    INTERVAL    Koc   (PPM )   (%DRIFT)     AREA    (IN)

--------------------------------------------------------------------

0.450(  4.261)  10   7    1894.0  350.0   GROUND( 6.4)  87.0   0.0

FIELD AND RESERVOIR HALFLIFE VALUES (DAYS)

--------------------------------------------------------------------

METABOLIC  DAYS UNTIL  HYDROLYSIS   PHOTOLYSIS   METABOLIC  COMBINED

(FIELD)  RAIN/RUNOFF  (RESERVOIR)  (RES.-EFF)   (RESER.)   (RESER.)

--------------------------------------------------------------------

396.00        2          N/A      2.50-  310.00    91.80     70.83

UNTREATED WATER CONC (MICROGRAMS/LITER (PPB)) Ver 1.1.1  MAR 26, 2008

--------------------------------------------------------------------

PEAK DAY  (ACUTE)      ANNUAL AVERAGE (CHRONIC)

CONCENTRATION             CONCENTRATION

--------------------------------------------------------------------

116.750                     19.777

 Wheel move, side roll, end tow, or hand move portable irrigation
systems.

	

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